Flexible Packaging Europe (FPE), the material-neutral European association representing suppliers of flexible packaging materials, welcomes the European Commission’s choice not to reopen Regulation (EU) 2025/40 on Packaging and Packaging Waste (PPWR) under the Environmental Omnibus and, instead, focus on prioritising the development of secondary legislation. FPE strongly urges the European Parliament and the Council to support the European Commission and continue protecting the integrity of such regulation.
The PPWR is a carefully balanced text resulting from years of technical work and political negotiation. Reopening it now would undermine legal certainty for businesses and EU competitiveness at the very moment when companies are preparing and already investing to comply with important obligations that will soon apply.
Legal certainty and focus on secondary legislation
“With several requirements entering into force shortly, what the industry needs to ensure it remains competitive is policymakers focusing legal certainty on the timely adoption of fair and workable secondary legislation,” says Karri Koskela, Chair of Flexible Packaging Europe, “In this light, we appreciate that the publication of the PPWR Commission notice and Frequently Asked Questions are seen as a priority – clarification on some provisions and definitions is urgently needed in addition to secondary legislation.”
Protecting key PPWR provisions that support competitiveness
Several core elements of the PPWR are crucial and must remain intact, according to FPE:
- Design for recycling (DfR) criteria: the obligation that “all packaging will have to be recyclable by design by 2030” places Europe at the forefront of circular packaging innovation. Clear, harmonised DfR rules are vital for long-term investment decisions and to avoid fragmentation of the Single Market. Flexible packaging converters are ready to provide recyclable structures for a wide variety of applications.
- Recycled content targets: Targets for recycled content boost the demand for recycled plastics, strengthen Europe’s recycling infrastructures and support investment in advanced technologies that will provide recyclates that can be even used for food applications. Without such targets, uptake of recycled plastics in packaging is at stake.
- Packaging minimisation: this is a core principle for resource efficiency and packaging waste reduction. Flexible packaging already delivers exceptional resource efficiency, with a packaging-to-product ratio 5 to 10 times lower than alternative solutions. The IFEU scenario analysis demonstrates that switching to flexible packaging could reduce the total weight of packaging used for non-beverage FMCGs in Europe by 21 million tonnes per year. Mandatory minimisation requirements support responsible material use and reflect FPE’s long-standing commitment to resource saving and decarbonisation.
FPE therefore calls on the European Institutions to ensure a stable regulatory framework and promptly develop the necessary guidance documents and secondary legislation that allow Europe’s packaging sector to remain innovative, competitive, and fully aligned with the EU’s circular economy objectives.

